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Seece said:

You could easily cheap swinging a 3DS on a bit of string?

If the sensors are anything good like a good real pedometer, you need to have a rather constant sinusoidal movement (the behavior of your pocket relative to the ground as the Y axis) for it to be "considered" a step.

That being said, you'll need a jumpy washing machine to fool a 3DS maybe, a string ain't gonna work unless you keep moving it too.

More practical, is to put the damn thing in your pocket.